A SURVEY OF EMERGENCY RESPONSE PLANNING AS PRACTICED IN BOILER INDUSTRIAL FURNACE FACILITIES BURNING HAZARDOUS-WASTE DERIVED FUELS/

Federal regulations require Boiler/Industrial Furnace (BIF) facilities which burn hazardous waste derived fuels (HWDF) to prepare contingenc y plans for dealing with on-site emergencies such as fires and explosi ons. Oklahoma environmental regulations broaden the scope of this plan ning of that of emergency response plans which include provisions for dealing with hazards that migrate off-site, such as hazardous material s releases. In developing specific guidelines to be used by permit app licants and reviewers in evaluating such response plans, a survey was conducted to identify current emergency response planning practices at BIF facilities burning HWDF. Contingency plans for 21 plants in 16 st ates were reviewed in detail, and it was concluded that: 1) the qualit y and completeness of plants varied greatly; 2) essentially all plans met minimum federal requirements, although to varying degrees of depth and detail; and 3) few plans included specific provisions for hazard assessment and response or for coordination with off-site agencies and affected communities; and 4) this planning ''gap'' could contribute t o uncoordinated and ineffective response by supporting agencies, with unnecessary exposure of responders or the general population to potent ially hazardous materials. Several exceptionally good plans addressed many planning considerations not required by federal regulations, and appeared to reflect the ''state-of-the-art'' in emergency planning at these facilities. These results support efforts to establish clear and specific emergency response planning guidelines for permit applicants and reviewers and to thereby ensure that adequate planning and coordi nation are achieved before operating permits are issued.